AI Generated Opinion Summaries

Decision Information

Citations - New Mexico Laws and Court Rules
Chapter 31 - Criminal Procedure - cited by 3,790 documents

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The petitioner was arrested on November 3, 1982, and charged with seven crimes. He remained in custody until his sentencing on July 19, 1983, as he did not meet the conditions of bail. The trial court sentenced him to 18 consecutive years of imprisonment and stated that he would receive credit for his presentence confinement. However, the exact amount of credit was not specified, leading to a dispute over the calculation of the presentence confinement period (paras 2-3).

Procedural History

  • Trial Court: The petitioner filed a motion for postconviction relief, requesting the trial court to determine the specific period of presentence confinement credit. The trial court denied the motion without a hearing (para 2).

Parties' Submissions

  • Petitioner: Argued that he was confined from November 3, 1982, to July 19, 1983, and should receive credit for the entire period. He claimed the Corrections Department lacked authority to calculate the credit and that only the trial court could determine the specific period (para 2).
  • Respondent (State of New Mexico): Contended that the petitioner’s claimed credit of 290 days was erroneous, as it exceeded the actual number of calendar days between arrest and sentencing. The respondent admitted being unable to calculate the correct credit due to insufficient records and requested either denial of the petition or remand to the trial court for determination (para 3).

Legal Issues

  • Is it mandatory for the trial court to specify the exact amount of presentence confinement credit under NMSA 1978, Section 31-20-12? (para 1)

Disposition

  • The Supreme Court of New Mexico held that it is the trial court's responsibility to determine the specific presentence confinement credit at the time of sentencing. The case was remanded to the district court for further proceedings in accordance with this opinion (para 5).

Reasons

Per Ransom J. (Sosa C.J. and Baca J. concurring):

The Court emphasized that under NMSA 1978, Section 31-20-12, the trial court must determine the specific amount of presentence confinement credit at the time of sentencing. This determination should be based on relevant documents or evidence made part of the record. The Court noted that the Corrections Department's calculations were insufficient and that the trial court is better positioned to resolve such matters using local records, such as those from the county jail or sheriff's office. The Court also clarified that the petitioner should not receive double credit for time served, as the presentence confinement period ends when parole is revoked (paras 4-5).

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